consistency between the modifications made to the facilities and those made to the documents used by the reactor control teams, such as operational control instructions and alarm sheets. It also ensures that the procedures used to configure the systems or lock out equipment do actually take account of the requirements arising from the STEs. Finally, it is attentive to the good understanding and good application of these various documents by the control teams and the correct management of sensitive activities, which are often the cause of anomalies. Failures to comply with the STE constitute significant events which are to be reported to ASN. ASN analyses the origin and consequences of these events and, during its inspections, checks that measures have been taken by the licensee to correct the deviations and prevent them from happening again. In 2021, ASN observes that the quality of monitoring in the control room remained at a satisfactory level, as in 2020, even if certain deviations this year are still the result of shortcomings in this monitoring. The number of system configuration deviations also remained at a level equivalent to that of last year. However, in 2021, the situations in which the reactor was operated outside the planned limits were far more numerous than in 2020 and returned to the level observed in 2019. Industrial activity in 2021, which was denser than in 2020 (reduced owing to the health crisis) no doubt partially explains this trend, but steps must be taken to limit these deviations and more broadly improve operating rigour in the facilities. The Covid-19 pandemic disrupted the training of the control teams in 2020 and 2021. ASN considers that the consequences of these disruptions on safety performance need to be analysed. In 2022, it will carry out an inspection campaign specifically on this topic. ASN checks that the periodic tests on equipment important for safety enable its correct operation and its level of performance to be checked. It carries out this verification when RGE modification authorisation applications are submitted. During inspections, it also verifies that these periodic tests are carried out in accordance with the test programmes stipulated in the RGEs. In 2021, the periodic tests were the cause of several significant events, owing to incorrect changes to test rules, inconsistency between the test rules and the rest of the RGEs, or inappropriate implementation of the test rules in the operating documents. With regard to OEF from these events, EDF is adapting its organisations to ensure better sharing of information between the various actors responsible for defining, programming and carrying out tests. Operation in an incident, accident, or severe accident situation ASN checks the processes to draft and validate the incident or accident operating rules, their pertinence and how they are implemented. ASN thus carried out several inspections in 2021 on the organisational and technical arrangements made by EDF to deal with an incident and accident situation. These inspections almost always include a situational exercise for the facility’s control teams in the room or on a simulator, to check the application of instructions and intervention and communication practices within these teams. Following these inspections, ASN considered that management of control situations by the control teams in the event of an incident or accident was satisfactory. In 2021, ASN also found that the EDF national engineering teams had done considerable work to correct errors and inaccuracies in the operating documents to deal with an incident or accident and which had been detected in recent years. ASN will be attentive to ensuring that the new process to correct deviations implemented by EDF will allow them to be rapidly dealt with, so that the deviations do not remain in the operating documents for long periods of time. Emergency organisation When the situation in the facility deteriorates or additional means are needed to manage the situation, the incident or accident operating procedures provide for activation of the PUI, which leads to deployment of an emergency organisation. In 2021, EDF activated its PUI for a transformer fire in the non-nuclear part of the Paluel NPP. The situation did not entail radioactive releases and did not require any population protection measures. In 2021, ASN carried out inspections on the EDF emergency organisation and resources. These inspections as a whole demonstrated that the NPPs have assimilated the principles of organisation, preparation and management of emergency situations to the extent that they can take the required action in the event of an emergency. ASN also underlines the professionalism and considerable motivation of the on-call personnel mobilised. However, following a change in the alert system, EDF must continue with its training efforts to guarantee that the crisis personnel assimilate the alert systems and it must make progress regarding the time taken to mobilise all the stakeholders. Finally, the through life support for a certain number of resources stored and deployable in an emergency situation must also be reinforced. 2.4.3 Maintenance of the facilities Preventive maintenance is an essential line of defence in maintaining the conformity of a facility with its baseline safety requirements. In order to improve the reliability of the equipment important for safety but also industrial performance, EDF is optimising its maintenance activities, drawing on practices used in conventional industry and by the licensees of NPPs in other countries. In 2008, EDF decided to deploy a new maintenance methodology, called “AP913”, developed by the American nuclear licensees and built around two main points: organisational changes to enhance monitoring of the reliability of the equipment and systems and implementation of a new type of preventive maintenance programmes. The AP913 implementation diagnostic performed by EDF in mid-2016 revealed difficulties with implementing performance monitoring and with increasing the maintenance tasks generated by the AP913 maintenance programmes. In 2017, EDF thus defined strategic guidelines for maintenance and reliability. It specified the roles of the various departments and professions related to the performance of maintenance, by reaffirming that the maintenance departments are responsible for the project ownership of the equipment they maintain, in particular in a context of continued operation of the reactors beyond 40 years. EDF also adopted function reviews to obtain an integrated view of the equipment and systems participating in each function, as well as a new phase of its project to control the volume of maintenance. Moreover, in response to the ASN request made in 2019, EDF submitted an authorisation application at the end of 2021 to add a new chapter to the RGEs, devoted to maintenance. 2.4.4 Assessment of maintenance Maintenance is an important topic, regularly checked by ASN during its inspections in the NPPs. The organisation within the NPPs for significant maintenance work was relatively satisfactory in 2021. However, ASN still 290 ASN Report on the state of nuclear safety and radiation protection in France in 2021 10 – THE EDF NUCLEAR POWER PLANTS
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